Sunday, December 22, 2013

United States v. Reynolds case brief

United States v. Reynolds case brief summary
345 U.S. 1 (1953)

CASE SYNOPSIS
Petitioner government appealed a judgment from the United States Court of Appeals for the Third Circuit in favor of respondents, pursuant to Fed. R. Civ. P. 37(b)(2)(i), on the issue of negligence of the deaths of respondents' civilian spouses in the crash of a military airplane upon government's refusal to produce government's official accident investigation report, asserting privileged military secrets.

CASE FACTS
Respondents brought action under the Tort Claims Act, 28 U.S.C.S. §§ 1346, 2674, for the deaths of their spouses in the crash of a military aircraft. They filed a motion for production of petitioner government's official accident report and the statements of the surviving crew members taken in connection with the official investigation. The government filed a motion to quash discovery, claiming privileged military secrets, which was denied. The Secretary of the Air Force subsequently filed a formal claim of privilege alleging that the aircraft and personnel were engaged in a highly secret mission.

PROCEDURAL HISTORY
The district court entered an order pursuant to Fed. R. Civ. P. 37(b)(2)(i) in favor of respondents on the issue of negligence. While the Tort Claims Act made the Federal Rules of Civil Procedure applicable to suits against government, Rule 37 imposed liability for refusal to produce matters not privileged.

DISCUSSION
The United States Supreme Court reversed, concluded that sufficient evidence existed to show that, during a time of vigorous preparation for national defense, a reasonable danger existed that the report contained references to privileged military secrets.

CONCLUSION
The Court reversed the appellate court's upholding the trial court's entry of liability against the government and remanded to the district court for further proceedings.

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